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Quality performance category will Carry 50% weight for 2018 performance year, which will reduce down to 30% in 2019 performance year.
Although the weight has been reduced to 50%, six measures are still required. One of these six meaures must be an Outcome measure or a High-Priority measure in lieu of it.
Quality data will need to be reported for full calendar year 2018 - Jan 1, 2018 to Dec 31, 2018. (up from 90 continuous days in 2017)
Data for the Quality performance category can be submitted using the EHR, Qualified Registry (QR), Qualified Clinical Data Registry (QCDR), CMS Web Interface (groups of 25 or more), Claims, and CAHPS for MIPS survey (additional submission method allowed).
Only one submission method allowed. Like 2017, clinicians will need to pick one submission method for the quality performance category in 2018 too. The option of using multiple submission methods for a performance category has been deferred until 2019 and will NOT be available in 2018. The measures available for reporting, and the benchmarks for the same measure via different submission methods may vary widely.
CAHPS for MIPS survey is the only exception to the 1 submission method rule. Eligible groups can report the CAHPS survey as one quality measure. The score for this measure will be calculated by determining the average score of the 8 Summary Survey Measures (SSM) scored for the CAHPS survey in 2018.
Variations for Individuals and Groups. The submission method options vary a little bit for individual and group submissions. Qualified Clinical Data Registries (QCDRs), Qualified Registries (QRs), and EHR are available for groups and individuals. Medicare Claims option is only available for individual submission, while CAHPS for MIPS and CMS Web Interface (groups of 25 or more) are only available for groups. For the Virtual Groups, all the submission options applicable to groups will apply.
To earn the maximum points available for a measure, 60% Data Completeness must be accomplished for all submission methods (except CMS Web Interface and CAHPS for MIPS).
For every quality measure, providers must submit data for at least 60% of the patients that qualify to be in the denominator for that measure.
CMS Web Interface and CAHPS for MIPS are each subject to a separate set of data completeness requirements as all the measures under these submission methods have to be reported.
Less than 60% data completeness will earn just 1 point in 2018 for all practices except small practices. Small practices (1 to 15 eligible clinicians) will still be able to earn 3 points for a measure if they fall short of the data completeness requirement.
High Priority and End-to-End Reporting Bonus. Both these bonuses will be scored just like in 2017. Only a max of 10% of the denominator can be earned for both types of bonuses. Total quality score cannot exceed 60 points (6 measures still required) including all the different bonus points.
Requirements to Earn High Priority Bonus Points. The High Priority measures include the outcome, appropriate use, patient safety, efficiency, patient experience, and care coordination measures. To be able to earn High Priority Bonus points for reporting these measures, the performance data reported must at least have a numerator of 1, a denominator of 20, and data completeness of 60%. Even if one of these criteria are not met for a measure, High Priority bonus points would not be awarded.
Measures Without Benchmark. Scoring approach for the measures with and without benchmarks remains the same as 2017. The measures that have a benchmark, begin with a floor of 3 points. Only 3 points can be earned for the measures that don’t have a benchmark or meet the case minimum requirements for the measure.
Topped Out Measures. Any measures identified as topped-out, would be phased out gradually in four years. Additionally, the measures that have been topped out for two consecutive years would earn only a maximum of 7 points even with 100% performance rate (not 10). This policy will not apply to the CMS Web Interface Measures for 2018.
The six topped-out measures that will be capped at 7 points in 2018 are:
1. Perioperative Care: Selection of Prophylactic Antibiotic-First or Second Generation Cephalosporin (Quality Measure ID: 21)
2. Melanoma: Overutilization of Imaging Studies in Melanoma (Quality Measure ID: 224)
3. Perioperative Care: Venous Thromboembolism (VTE) Prophylaxis (When Indicated in ALL Patients) (Quality Measure ID: 23)
4. Image Confirmation of Successful Excision of Image-Localized Breast Lesion (Quality Measure ID: 262)
5. Optimizing Patient Exposure to Ionizing Radiation: Utilization of a Standardized Nomenclature for Computerized Tomography (CT) Imaging Description (Quality Measure ID: 359)
6. Chronic Obstructive Pulmonary Disease (COPD): Inhaled Bronchodilator Therapy (Quality Measure ID: 52)
Out of these 6 measures, 5 are high-priority measures and are all available for submission via Qualified Registries, whereas only 3 are available for submission via Claims.
Topped Out Measures Vary by Submission Methods. Based on 2015 historic benchmark data, approximately 45% of the current quality measure benchmarks currently meet the definition of topped out. The approximate percentage varies for different submission methods though.
• 70% of Claims measures are topped out
• 10% of EHR measures are topped out
• 45% of Registry/QCDR measures are topped out
Number of Measures Required. Most clinicians will need to submit 6 measures (just like in 2017), where one measure is an Outcome measure or a High Priority measure in lieu of it. Eligible clinicians (ECs) can report more than 6 measures. CMS will use the six measures with highest points to calculate the Quality performance score. All 14 measures are required for those utilizing CMS Web Interface. Those who are participating in MIPS APMs will have distinct measure reporting requirements based on the specific MIPS APM they are participating in. MSSP and Next Gen ACO participants are required to utilize CMS Web Interface measures, whereas the participants of Oncology Care Model, Comprehensive ESRD Care, and Comprehensive Primary Care Plus (CPC+) have different measures defined for submission.
Determine Maximum Achievement Points. For most of the providers, the maximum points will be 60 for the 6 required measures (Number of measures required x 10), unless the Specialty Measure Set that has less than 6 measures, the All-Cause Hospital Readmission Measure is applicable, or the group is reporting via CMS Web Interface.
Calculate Achievement Points. A maximum of 10 points can be earned for each of the six measures, if the case minimum and data completeness is met for a measure that has a benchmark. It’s noteworthy that maximum points for 6 of the topped-out measures have been capped at 7 points.
Calculate the Bonus Points. This includes the high priority bonus points (Outcome, High Priority, and Patient Experience Measures) and the CEHRT bonus points (end-to-end reporting). Both the high priority and CEHRT bonus points are capped at 10% of the maximum achievement points each. If the maximum points are 60, you can only earn 6 bonus points each.
Performance Improvement Bonus. Up to 10 percentage points can be earned towards the Quality performance score for an improved performance in 2018 as compared to 2017. Read How Quality Improvement Scoring Works
Quality Performance Category Score. Only a maximum of 100% score can be earned including all the bonuses and the Quality Performance Improvement bonus. Beginning 2018, the Quality category points will be expressed as a percent. These points will then be multiplied by the Quality category weight (50) to determine the Quality category score.
Final MIPS Score. This quality category score will be added with other performance category scores, the complex patient bonus, and the small practice bonus to arrive at the final MIPS score.
The Promoting Interoperability (PI) performance category will carry 25% weight in 2018 (same as in 2017).
Clinicians have to report for a minimum of 90 consecutive days in the performance year 2018 for the PI category. They can choose to report for any additional duration up to a full calendar year.
Data for the PI performance category can be submitted by attestation, or by utilizing EHR, Qualified Registry, QCDR, or CMS Web Interface (groups of 25 or more) methods.
As the data pertains to the use EHR, only clinicians utilizing a 2014 or 2015 edition certified EHR can submit the data.
Certain exclusions and exceptions are available for MIPS eligible clinicians if they are faced with certain circumstances. It’s important to understand the basic difference between the two.
EXCLUSIONS – Available to all the eligible clinicians who report data for the PI category if they meet certain criteria defined for certain measures. For instance, exclusion can be claimed for the E-Prescribing measure, by a MIPS eligible clinician who writes fewer than 100 permissible prescriptions during the performance period. Claiming the exclusion allows the eligible clinicians to complete the PI base requirements and earn an PI score. Claiming an exclusion does NOT reweight the PI category to 0%.
However, exclusion CANNOT be claimed for Security Risk Analysis. It has to be completed in order to complete base requirements and earn a PI score.
EXCEPTIONS – On the basis of provisions in the 21st Century Cures Act and MACRA, CMS will reweight the PI category to 0% and its weight (25%) assigned to the Quality performance category in the following situations:
a. Automatic Reweighting: The PI category will automatically be reweighted to 0% without submitting any application for:
- Hospital-based MIPS eligible clinicians (now includes covered professional services furnished by MIPS eligible clinicians in an off-campus-outpatient hospital)
- Non-Patient-Facing clinicians or groups with >75% NPF clinicians (eligibility determination based on the E&M codes and the surgical and procedural codes utilized by the clinicians)
- Ambulatory Surgical Center (ASC) based MIPS eligible clinicians (will also apply in 2017)
- MIPS eligible Physician Assistants, Nurse Practitioners, Clinical Nurse Specialist, and Certified Registered Nurse Anesthetists
b. Reweighting by Hardship Exception Application: Eligible clinicians can submit an application by Dec 31, 2018 to claim the hardship exception and get the PI category reweighted to 0%
- Small Practices (1-15 eligible clinicians) facing overwhelming barriers to adopting a certified EHR (new hardship exception introduced in 2018)
- Clinicians whose EHR got decertified during the performance year (will also apply in 2017)
- MIPS Eligible Clinicians facing significant hardship defined as:
-- Have insufficient internet connectivity
-- Extreme and uncontrollable circumstances (e.g. Natural Disasters)
-- Lack of control over the availability of certified EHR technology
There are two PI measure sets available for the eligible clinicians and groups to choose from:
1. PI Objectives and Measures: 2015 Certified Edition EHR, or a combination of 2014 and 2015 EHR editions is required to choose this option.
2. 2018 PI Transition Objectives and Measures: This is the only option if for reporting using a 2014 edition EHR.
The same amount of points can be earned using either option for base and performance measures. However, an additional bonus of 10 points is available for exclusively using the 2015 edition EHR for capturing and reporting PI performance using the “PI Objectives and Measures” set.
The Promoting Interoperability (PI) score is made up of 3 parts.
Base points (50 points) + Performance points (max 90 points) + Bonus points (max 25 points). Although these points total up to 165 points, the max points are capped at 100.
The base score requirements remain the same as in 2017. That means, all of the base measures would need to be reported (either by submitting the data or by claiming an exclusion) to get any points in the PI performance category.
PI Scoring Changes in 2018
- 10% Bonus for Exclusive Use of 2015 Edition EHR
Eligible clinicians can continue to use 2014 Edition Certified EHRs in 2018. They can even use both 2014 and 2015 editions if ECs are transitioning to a 2015 Edition Certified EHR. However, clinicians who exclusively use 2015 Edition Certified EHR for the entire performance year will receive a 10% bonus towards PI performance category score.
- Additional Improvement Activities for 10% PI Bonus Available
More improvement activities are eligible in 2018 for 10% bonus in the PI category if they are reported using certified EHR technology (CEHRT) as compared to 2017.
- 10 Points for Any Clinical Registry Reporting
Submitting data to any one clinical data registry or public health agency will be awarded 10 points under the performance score. This now opens up options for the clinicians to report to the registry that is relevant to their specialty/practice. (In 2017, providers could only earn these 10 points by submitting data to an immunization registry.)
- 5 Points for Additional Clinical Registry Reporting
Providers can still report to an additional clinical registry (not reported under the performance score) to earn 5 bonus points in the PI category.
The weight for the Improvement Activities (IA) performance category stays the same as in 2017, at 15%.
Under the IA performance category, Clinicians have to report for a minimum of 90 consecutive days in the performance year 2018. More than 90 days (up to a full calendar year) of data can be submitted if desired. No additional points are awarded for submitting data pertaining to more than 90 days.
However, if for adequately performing and documenting an Improvement Activity, it took you more than 90 days, then it is advisable to report it for more than 90 days.
Data for the IA performance category can be submitted either via EHR, Qualified Registry, a QCDR, or by Attestation.
The scoring for IA category in 2018 will work in the same manner as in 2017. A maximum of 40 points can be earned based on a selection of different medium and high-weighted activities.
Small practices, and the practices in rural and HPSAs will still be able to earn double the points for both the medium and high weight activities. 40 points equate to 100% performance in the IA category, translating to maximum category score of 15 points. These 15 points will count towards the calculation of final MIPS score.
MIPS Score = IA Score + PI score + Cost Score + Quality Score + Complex Patient Bonus + Small Practice Bonus (if applicable)
If a practice is reporting as a group, only one MIPS eligible clinician in the TIN has to perform the Improvement Activity for the TIN to get the credit for the activity performed. The same holds true for Virtual Groups too.
Additional Improvement Activities Available for Reporting
For 2018, there will be 112 improvement activities available to pick from, an increase from 93 activities available for 2017 reporting (1 activity removed). More improvement activities that are eligible for bonus under PI category are available in 2018. Changes have been made to 26 of the existing improvement activities. So, even if you plan to report on the same activities that you reported for 2017, it would be wise to revisit the activities and check for any changes in the requirements.
PCMH 50% Threshold Needed for Full IA Credit
For a TIN to get a full credit for Improvement Activities, at least 50% of the practice sites within the TIN need to be recognized/certified as Patient Centered Medical Homes (PCMH).
(In 2017, only 1 practice site being considered as PCMH sufficed to earn IA full credit for a TIN.)
Cost category will carry 10% weight towards final MIPS score in 2018. Only two measures will be assessed for 2018:
- Medicare Spending Per Beneficiary (MSPB)
- Total Per Capita Cost for all attributed beneficiaries
The performance under the Cost category will be assessed for the complete calendar year (Jan 1, 2018 – Dec31, 2018) or 365 days.
No submissions will be required for the Cost category.
CMS will assess the performance from the Administrative Claims data for the entire calendar year 2018.
Similar to the calculation of Quality performance category score, the Cost score would be calculated by comparing performance against benchmarks and the points will be assigned on a decile system. However, the benchmarks for Cost measures will be based on the same year’s performance unlike the Quality benchmarks which are based on historical performance.
Each measure will be scored only if the reporting entity meets the case minimum requirement for the measure. For 2018, the minimum number of cases required for each measure are:
- Medicare Spending Per Beneficiary (MSPB) – minimum of 35 cases
- Total Per Capita Cost for all attributed beneficiaries - minimum of 20 cases
The cost category score would be determined by calculating the average of the performance on both the above mentioned measures.
If only one measure can be scored, the performance on that measure will determine the Cost category score.
If both the measures can't be scored, the Cost category weight would be reallocated to the Quality performance category. When that happens, Quality category will account for 60% of the MIPS score. Learn more about MIPS 2018 Cost Category
Following the Bipartisan Budget Act of 2018 (HR 1892) enacted on Feb 9, 2018, the performance improvement for Cost category will not be considered for 2018 MIPS score calculations.